Background

On 26 May 2026, MAS published an information paper highlighting critical observations and good practices for overall fair dealing with customers, following a survey of financial institutions (“FIs”). FIs are required to maintain robust internal controls to safeguard consumer interests and ensure fair dealing outcomes. This paper covers 4 broad areas: prospecting and advertising activities, advisory and sales processes, safeguards for sales to vulnerable customers and complaints handling processes and references the MAS Fair Dealing Guidelines (“FDG”).

Regulatory Expectations

1. Roadshow Activities: Under Outcome 3 of the FDG, FIs must ensure their representatives avoid aggressive sales tactics and allow customers enough time to understand and consider recommendations. This helps prevent harassing marketing practices and ensures customer feedback is addressed promptly.
   
   
2. Digital Marketing and Advertising: Safeguard 4 of the Guidelines on Standards of Conduct for Digital Advertising Activities requires FIs to maintain effective oversight and monitoring of digital marketing activities. Key controls include making representative’s identities known, prior approval for self-created marketing materials, regular sample reviews of social media posts, and enhanced scrutiny of representatives with prior social media-related complaints or misconduct.
   
   
3. Support for Representative-Customer Engagement: FIs, under Outcome Three of the FDG, must implement robust training and competency programmes to equip representatives with the skills to conduct proper fact-finding and provide suitable advice, while ensuring fact-find forms and risk profiling questionnaires capture all relevant customer information. This helps detect discrepancies in customer information during the financial needs analysis and ensures customers understand key product features and risks
   
   
4. Vulnerable Customer Protections: Outcome Two of the FDG states that FIs must implement specialized supervisory checks and mandatory secondary reviews for transactions involving Selected Clients,  ensuring product complexities are fully understood and prevention of mismatched or unsuitable product offering to these clients.
   
   
5. Complaints Handling: Under Outcome Five of the FDG, FIs are expected to use independent, competent functions to investigate complaints objectively, ensuring that systemic representative misconduct trends are reported immediately to the BSM and resolved through appropriate remediation actions.
   

What’s Next?

Management must anticipate more frequent supervisory spot-checks and thematic inspections regarding street-level and digital marketing compliance. FIs must actively upgrade their middle-office surveillance scripts, update internal training materials, and prepare for tighter regulatory parameters tracking client-representative interactions.

How Can We Help?

Capital Governance assists Financial Institutions through:  

1. Refreshing P&Ps: Conduct a gap analysis and proposing tailored structural improvements and policy enhancements to ensure compliance with FDG.
   
   
2. Digital Advertising Conduct Audits: Reviewing marketing, onboarding, and sales scripts to ensure full alignment with Guidelines on Standards of Conduct for Digital Advertising Activities and Fair Dealing principles.
   
   
3. Balanced Scorecard Audits: Post-transaction audits to ensure proper advice given by representatives, especially for vulnerable customers.
   
   
   and more …